Joint Broadband Technology Opportunities Program Request for Information

March 12, 2009
Docket Number: 

American Recovery and Reinvestment
Act of 2009 Broadband Initiatives

Michael W. Krajovic

(Late Submission)
Comments Being Submitted by the Following Groups:

Michael W. Krajovic, CEcD
President & CEO
Fay-Penn Economic Development Council
Two West Main Street, Suite 407
Uniontown, PA 15401
Phone: 724-437-7913
Fax: 724-437-7315

Andrew P. French, Executive Director
Redevelopment Authority of the
County of Fayette, Pennsylvania
86 West Main Street
Uniontown, Pennsylvania 15401
Phone: 724-437-1547 ext. 210
Fax: 724-437-0731

J. Michael Edwards
Executive Director
Connellsville Redevelopment Authority
124 West Crawford Avenue
Connellsville, PA 15425
724 626 1645

Richard Ellsworth
American Broadband
1321 Connellsville Road
Lemont Furnace, PA 15456
Office: 724-437-1042 ext. 6320
Mobile: 251-753-9061

These groups are in support of the comments that follow.
These comments are for (Docket No. 090309298-9299-01)
American Recovery and Reinvestment Act of 2009 Broadband Initiatives

- Education should be the number one priority for determining deployments, over immediate economic development and commercial interests. School buildings may have broadband capabilities, but children need access at home to do internet research and improve communication between the school and the home. Higher education attainment of students will lead to ‘across the board’ benefits to all levels of businesses, and economic development both in the short and long terms. Deployment areas should coincide with local school districts provided that the school has broadband capabilities.

- Additional priority should be given to projects which will expand service to areas that currently do not have any access to broadband services or areas where the current broadband service is not able to meet a community’s advanced communication service needs. Priority should be given to these types of projects rather than to projects which will simply rebuild existing broadband systems.

- The program must include grant funding to determine:

1. Feasibility study on best technology for a given area that is the most cost-effective.
2. Determine best interface with existing telecom providers, cable companies and others that may already be in small towns and suburbs, but do not provide service to rural and less densely populated areas.
3. Feasibility study for best management, operation and maintenance of the recommended system.
4. If the feasibility study applicant is a for-profit company they must demonstrate that they are working and partnering with local government agencies, local planning office and other non-profit groups that work in the economic development field within that project scope of work.
5. Study for determining price structure for different categories of users.
6. Study for determining total cost for deployment and determine loan/grant combination needed to make the broadband technology affordable to rural households and businesses.
7. Ongoing subscriber fees which should take into consideration per capita incomes.

- Each state should develop a list of consultants who are qualified to address the 7 items above.

- The grant funding for conducting a feasibility study should include small (10%) local match and in some cases, include in-kind matching support.

- Federal regulations should require cooperation by all commercial carriers everywhere to support system expansions, interfaces with existing commercial systems, and for commercial carriers to support local expansions by being willing to function as the broadband systems operating and maintenance company. Commercial companies are quick to install services in densely populated communities, but almost always refuse to deploy in rural areas with limited number of subscribers.

- The broadband deployment program should work similarly to the RUS programs in USDA where each project is analyzed for proper grant and loan ratios based on per capita incomes.

- Thought should be given to strongly encouraging high levels of public participation, but it must also be affordable - $20/month. It will be impossible for local communities to commit to assuming loan obligations without some guarantee to ensure subscribers. Perhaps the subscriber fees could be paid partially by another local taxing body such as a school district or municipality.

- Due to uniqueness of each area, flexibility should be provided to allow for multiple ownership models of local systems such as local government, non-profits, public authorities, local cooperatives, etc.

- Public funds should not be provided freely to existing commercial carriers without proper federal regulations to limit benefits to reasonable rates of return, and ensure maximum benefit for the public good.

- The federal government and the states should consider forming one state public authority for each state to serve as the central coordinating body with certain powers to manage interfaces with existing commercial carriers and to improve deployments via economies of scale and other technical and operating efficiencies. This could be one large rural cooperative/authority.

- The federal government could provide templates for local communities to use as RFP’s for selecting consultants.

- The federal government could provide templates for local communities to form local cooperatives, for contracting with private companies for operating and maintenance, and for interfacing with existing carriers.

- Grant and loan levels to fund broadband systems should range from $250,000 up to $10 million. Engineering fees to final deployments and systems design should be eligible costs. The grant should require a minimum of number of subscribers per investment to help ensure that the largest number of people served for each dollar invested. Small rural towns with higher concentrations of residents and businesses would take precedence.

- For remote locations, satellite hook-ups might be only cost effective alternative, but people could receive federal tax credits as incentives to increase installments and usage.

- Developing a national map should be a priority. The map should provide enough detail to be functionally useful in planning new deployments in underserved areas. GIS level of detail should be standard. Many commercial users have a reputation of providing unreliable data showing geographic coverage’s. Maps should be updated every 5 years. Major commercial carrier for license renewable or perhaps even annually, should be required to submit detailed maps of changes in coverage.

Broadband Comments being submitted by the following groups 4-13-09.docx 19.51 KB

PAETEC Communications, Inc.

(Late Submission)
See attached document that was submitted by email on April 13, 2009.

PAETEC NTIA-FCC Comments 041309.DOC 39 KB

"Darrel Kirkland" <>

(Late Submission)
Please put me on the list.

Also, I'd like to attend the public meeting on the 23rd. Do I need to
register, and where?


Darrel Kirkland
Kirkland & Associates

Andrew Beard

(Late Submission)
Please see the attached comments from CoverageCo.

CoverageCo Comments on ARRA.pdf 821.58 KB

EvenLink, LLC Partner Scott Musser

(Late Submission)
On behalf of EvenLink, LLC, we greatly appreciate the NTIA allowing the public to comment on this significant process. Please refer to the attached PDF re: Comments to the National Telecommunications and Information Administration and the United States Department of Agriculture Rural Utility Service on Rules for Broadband Grants and Loans

NTIA Comments 4 13 09 Final2.pdf 26.16 KB

"Baker, Jim" <>

(Late Submission)
Since there has been very limited funds availability for planning
purposes over the last far-too-many years, is there any thought to
funding such planning in the first grant round? In other words, the
'plans' we have are still just dreams. Will we ever have a chance to
see if those dreams can ever be implemented?

James L. Baker, Chief

Information Technologies Group

SEDA - Council of Governments

201 Furnace Road

Lewisburg, PA 17837

voice: (570)524-4491 fax: (570)524-9190

"My job in the coming years will not be to attract companies... my job
will be to attract talent."
- Janet Miller, Nashville Area Chamber of Commerce

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Jenifer Simpson

(Late Submission)
Comment is an attached document in Word "COAT Comments to NTIA on ARR Broadband Stimulus."

COAT COMMENTS TO NTIA on ARR Broadband Stimulus.doc 327.5 KB

"Ken Pavloski" <>

(Late Submission)
Please forward any information available as to time and location of the
Broadband Technology Opportunities Program meetings to be held in
Flagstaff AZ, and Las Vegas, NV. Also please advise if these are open
forums, or if pre-registration is a requirement. If pre-registration is
necessary, please also provide materials required to do so.

Thank you,

Ken Pavloski

Developmental Design Engineer

Advanced Products Group

Pima, Arizona

982-792-2819 Office

982-792-8194 Mobile

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"NTIAHelpDesk NTIAHelpDesk" <>

(Late Submission)

NTIA Help Desk
Department of Commerce
National Telecommunications and Information Administration
Office of Spectrum Management
Herbert C. Hoover Building (HCHB)
U.S. Department of Commerce / NTIA, Room 4625
1401 Constitution Avenue, N.W.
Washington, D.C. 20230
Office: 202-482-4631

>>> "Kliethermes, Sarah" 4/14/2009 12:47
PM >>>

I submitted the attached Comment yesterday, on behalf of the State of
Missouri, via the email address '' , and wanted
to confirm its inclusion in the record. The current record for the
State of Missouri is illegible.

Thank you,
Sarah L. Kliethermes
MoBar# 60024
Legal Counsel
573 751-6726
Fax 751-9285

From: Kliethermes, Sarah
Sent: Monday, April 13, 2009 2:58 PM
To: ''
Cc: Kliethermes, Sarah; Dietrich, Natelle*; Luebbert, Mary
Subject: American Recovery and Reinvestment Act of 2009 Broadband
Initiatives - Comments of the State of Missouri

Please find attached the comments of the State of Missouri.

Thank you,
Sarah L. Kliethermes
MoBar# 60024
Legal Counsel
573 751-6726
Fax 751-9285

NTIA comments 20090413.pdf 89.71 KB

Fiber-To-The-Home Council

(Late Submission)
Comment is over 10,000 characters. Submitting as attachment.

FTTH Comments (NTIA) Docket No. 090309298-9299-01.pdf 2.76 MB

Gregory Rosston

(Late Submission)
Comments of 71 Concerned Economists
Using Procurement Auctions to Allocate Broadband Stimulus Grants (See Attached file)

2009-4-13_Procurement_auctions_for_bbd_stimulus final.pdf 231.61 KB

Bryan Darr

(Late Submission)
Please see attachments.

ProductsAndServices_v200901.pdf 1.99 MB
CellMaps_v200901.pdf 1.2 MB
WISARD_v200901.pdf 999.54 KB
AR_BTOP_InformationalFiling.pdf 145.61 KB
AR-MB_Sample_Broadband_Map.jpg 196.27 KB

Governor Corzine (NJ) and Governor Rounds (SD)

(Late Submission)
See attached .pdf file

BB Filing to NTIA RUS 041309.pdf 940.22 KB

Clearwire Corporation

(Late Submission)
Attached please find the comments of Clearwire Corporation.

Clearwire NTIA-RUS Comments Final.pdf 55.16 KB

"Verlyn Veldhouse" <>

(Late Submission)
We would love to have any additional information on the "correspondence
list for the Broadband Technology Opportunities Program (BTOP)" as
indicated on the web site for todays webcast. Additionally thanks for
having this on a webcast - we just could not justify flying to DC for an
hour meeting.

Verlyn Veldhouse,
Vice President

Your Total Communications Solution Provider
14910 Grover Street
Suite 300
Direct 402-938-5115
Office 402-597-3333
Fax 402-597-3577
Alternate 800-824-1636

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att4ab45.bmp 10.52 KB
att4ab46.bmp 22.48 KB

(Late Submission)
On behalf of the NHISPA, attached are our comments for submission in
NTIA/RUS Docket No. 090309298-9299-01. Please contact me if you have any
questions concerning this filing.

Carol Miller
38 Glen Avenue
Berlin NH 03570
V: 603-752-1250 Ext 11
F: 603-752-8134

NHISPA41309.doc 23.5 KB

"Eric Jensen" <>

(Late Submission)
Barbara Brown:

I would like to submit the attached statement on behalf of the National Tribal Telecommunications Association, comprised of the only 8 Indian Tribes (from 563 tribes) that have created their own regulatory telecommunications companies. NTTA is deeply concerned that the Broadband stimulus monies will not reach the communities that need broadband (and voice dialtone) connectivity the most: Indian Tribes. Included in our submission are specific positive recommendations for solutions that will balance out the imperative of the Department of Commerce, the Federal Communications Commission and the Department of Agriculture to reach the widest population in rural areas with communities that will never benefit from market force or private investment.

If you have any questions, please do not hesitate to contact me.

With Best Regards,

Eric Jensen
Policy Counsel
National Tribal Telecommunications Association, and,
Four Horizons Development Company
First Tribal Liaison Officer for the Federal Communications Commission
519 Tennessee Ave
Alexandria, VA 22305
(703) 683-3742
pcs: (703) 868-8325

NTTA Broadband Stimulus funding 43 KB
NTTA Broadband Stimulus funding 43 KB


(Late Submission)
Please find attached GVNW's response to the joint request for information.

Please contact me if there are any questions.


Jeffry H. Smith
Vice-President and Division Manager, Western Region
Chairman of the Board of Directors

BTOP41309.pdf 112.54 KB

Professor Michael Botein

(Late Submission)
See attachment.

ACF7B5F.pdf 75.67 KB

"Alexander J. Bryson" <>

(Late Submission)
To Whom It May Concern:

The comments from 3G Americas on the National Telecommunications and
Information Administration and Rural Utilities Service queries regarding
the American Recovery and Reinvestment Act of 2009 Broadband Initiatives
are attached in Microsoft Word form. Please contact me, Alex Bryson,
via phone at 202-730-1319 or e-mail at if
there are any problems regarding this filing.

Thank you very much for your time.

Alex Bryson

Legal Assistant

Harris, Wiltshire & Grannis LLP

1200 Eighteenth Street NW

Washington DC, 20036

(202) 730-1319

3G America Comments to NTIA and RUS 4.13.09 125.5 KB

"Daniels, Emily J. H." <>

(Late Submission)
Attached, in both Word (.doc) and Adobe (.pdf) formats, are the comments
of the MSS & ATC Coalition in response to the joint NTIA and RUS request
for information.
<> < NTIA-RUS Comments.pdf>>

Emily J. H. Daniels | Pillsbury Winthrop Shaw Pittman LLP
Tel: 202.663.9378 | Fax: 202.663.8007
2300 N Street, NW | Washington, DC 20037-1122



The contents of this message, together with any attachments, are intended only for the use of the individual or entity to which they are addressed and may contain information that is legally privileged, confidential and exempt from disclosure. If you are not the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this message, or any attachment, is strictly prohibited. If you have received this message in error, please notify the original sender or the Pillsbury Winthrop Shaw Pittman Help Desk at Tel: 800-477-0770 x4860 immediately by telephone or by return E-mail and delete this message, along with any attachments, from your computer. Thank you.

MSS-ATC Coalition NTIA-RUS Comments.doc 89 KB
MSS-ATC Coalition NTIA-RUS Comments.pdf 37.6 KB

"James Groft" <>

(Late Submission)
Filing comments in the above referenced docket.

James Groft, CEO
Northern Valley Communications
(605) 725-1000

NTIA-RUS Rules Comments 4.9.09.pdf 212.33 KB

Susan Estrada

(Late Submission)
FirstMile.US is pleased to have the opportunity to comment on the BTOP and RUS programs.

FirstMileUScomments.doc [Compatibility Mode].pdf 547.79 KB

National Association of Regulatory Utility Commissioners

(Late Submission)
I've attached [1] NARUC's letter signed by 90 commissioners representing 39 states [2] a handout hand-delivered to several NTIA/RUS staff with specific comments from several states [3] two related letters filed in this proceeding by two additional commissions endorsing key aspects of the NARUC filings.

090303 NTIA RUS FINAL 90 CMRS 39 STATES.pdf 3.2 MB
KS 4-2-09 NARUC Response Ltr.pdf 42.57 KB
09 0401 PUCO Broadband Letter _2_.pdf 157.96 KB
09 0319 RV NTIA Advocacy Materials _2_.pdf 126.61 KB

"Galen Updike" <>

(Late Submission)

Attached find State of Arizona - Government Information Technology
Agency (GITA) response to the NTIA RFI.

Galen Updike

Telecommunications Development Manager

Government Information Technology Agency (GITA)

State of Arizona

100 N. 15th Ave, Suite 440

Phoenix, AZ 85007

(602) 364-4794

GITA Response to NTIA RFI April 13 2009 _2_.pdf 241.47 KB

Walt Lessun

(Late Submission)
Public comments from Walt Lessun:

6. Grants for Expanding Public
Computer Center Capacity: The
Recovery Act directs that not less than
$200,000,000 of the BTOP shall be
awarded for grants that expand public
computer center capacity, including at
community colleges and public
a. What selection criteria should be
applied to ensure the success of this
aspect of the program?

Select the poorest, most isolated Community Colleges and Public Libraries for implementation, then work upwards

b. What additional institutions other
than community colleges and public
libraries should be considered as
eligible recipients under this program?
Whatever is the equivalent of Michigan’s system of Regional Educational Media Centers. At least the REMC serving the western Upper Peninsula already provides a fiber network used for Interactive Television links to Intermediate School Districts, School Districts and school buildings in the service area.

9. Financial Contributions by Grant
Applicants: The Recovery Act requires
that the Federal share of funding for any
proposal may not exceed 80 percent of
the total grant.8 The Recovery Act also
requires that applicants demonstrate
that their proposals would not have
been implemented during the grant
period without Federal assistance.9 The
Recovery Act allows for an increase in
the Federal share beyond 80 percent if
the applicant petitions NTIA and
demonstrates financial need.
a. What factors should an applicant
show to establish the ‘‘financial need’’
necessary to receive more than 80
percent of a project’s cost in grant

Please consider a blanket waiver of the 80/20 proportion. Rural poor do not have dollar matches. Most of us will have to have the grants pay for staffing and equipping and expanding existing facilities to serve a broader public. Some may even have to construct additions to existing buildings to expand capacity.

b. What factors should the NTIA
apply in deciding that a particular
proposal should receive less than an 80
percent Federal share?

Just assume that most applicants will be poor enough to quality for zero match.
VerDate Nov<

c. What showing should be necessary
to demonstrate that the proposal would
not have been implemented without
Federal assistance?


11. Reporting and Deobligation: The
Recovery Act also requires that grant
recipients report quarterly on the
recipient’s use of grant funds and
progress in fulfilling the objectives of
the grant proposal.13 The Recovery Act
permits NTIA to de-obligate funds for
grant awards that demonstrate an
insufficient level of performance, or
wasteful or fraudulent spending (as
defined by NTIA in advance), and
award these funds to new or existing
a. How should NTIA define wasteful
or fraudulent spending for purposes of
the grant program?

Rely on applicable state statute definitions or definitions provided by the current edition of Black’s Law Dictionary

b. How should NTIA determine that
performance is at an ‘‘insufficient

Establish minimum operational levels for the public computing centers and request confirmation from the reporter that those minimums were met. Require traffic reports from the internet service providers showing that congestion limits were not exceeded during the reporting period with a natural disaster exemption

c. If such spending is detected, what
actions should NTIA take to ensure
effective use of investments made and
remaining funding?

Regional monitors of the program should be sent to the grantees with specific directions to correct problems.

12. Coordination with USDA’s
Broadband Grant Program: The
Recovery Act directs USDA’s Rural
a. For purposes of the BTOP, how
should NTIA, in consultation with the
FCC, define the terms ‘‘unserved area’’
and ‘‘underserved area?’’

If the area is not served by at least two 100 gig backbones and the right number of 10gig pipelines it’s underserved. If there are no backbones in the service area, it’s unserved.

b. How should the BTOP define
‘‘broadband service?’’

100gig backbones, 10gig pipelines scalable
(1) Should the BTOP establish
threshold transmission speeds for
purposes of analyzing whether an area
is ‘‘unserved’’ or ‘‘underserved’’ and
prioritizing grant awards?


thresholds be rigid or flexible?

Flexible but with rigid minimum requirements

(2) Should the BTOP establish
different threshold speeds for different
technology platforms?

Yes but with minimums

(3) What should any such threshold
speed(s) be, and how should they be
measured and evaluated (e.g., advertised
speed, average speed, typical speed,
maximum speed)? Minimum speeds and maximums capacities scalable as bandwidth is needed

(4) Should the threshold speeds be
symmetrical or asymmetrical?


(5) How should the BTOP consider
the impacts of the use of shared
facilities by service providers and of
network congestion?
Measure public use and measure public satisfaction with support, maintenance and training programs. Network congestion can be managed by the ISP(s) service provider by setting minimally acceptable congestion parameters (redlines) and plans to expand capacity when those minimums are not consistently met on a daily basis

15. Please provide comment on any
other issues that NTIA should consider
in creating BTOP within the confines of
the statutory structure established by
the Recovery Act.

Sustainability of the public computing centers: rural community colleges in Michigan have been doing more with less since the 1970‘s. We have trimmed staff, combined units, slashed budgets. Rural public libraries are systemically underfunded: taxable land is assessed for agricultural value, forested lands are either federal, state (no taxes) or favored enterprise (reduced taxes) owned and most state funding formulae are population based. Where will rural public computing centers get the money to staff themselves, pay for training programs, pay for computing system upgrades, software, maintenance…? How will a return on this investment be measured. How will revenues be generated to continue services past the grant period?
VerDate Nov<

Public comment questions.docx 17.34 KB
Public comment questions.docx 17.34 KB

"Derek E. Brooks" <>

(Late Submission)
Q: Earlier in this Webcast, I believe that Ms. McGuire-Rivera mentioned
briefly that the inclusion of the 'Socially and Economically Disadvantaged'
business community would be given a substantial consideration during the
Broadband Grant proposal process. No doubt, particularly during this
extremely challenging economic period, this would be a tremendous point of
participatory encouragement to this sector of the business community.

Can you briefly expand on that premise, and/or provide any further
authoritative guidance on this important point, so that members of this
particular sector of the business community that operate generally within
the Broadband arena can guide themselves accordingly - perhaps through the
pursuit of strategic relationships in that regard?

Many thanks.


Derek E. Brooks

President & Chief of Operations


85 Rangeway Road, Floor #1

Billerica, MA 01862

(781) 367-9881 - Direct

Full Service Telecom/Datacom Network Infrastructure SOLUTIONS

*Please Note New ICI Address, & Contact Information!

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Lawrence A. Jacobson

(Late Submission)
See attached.

Nebraska broadband letter of support.doc 200 KB

Kevin Anderson

(Late Submission)
Please see attached

RuralUtilsService.doc 26.5 KB

Charles Benton

(Late Submission)

Benton_grant_criteria_4-1-09.pdf 74.21 KB

Luisa Handem

(Late Submission)
See attachment


The Public Safety Spectrum Trust Corporation

(Late Submission)
See attached file.

PSST BTOP Comments (04-13-09).pdf 43.11 KB

Rim Semiconductor

(Late Submission)
see attachment

NTIA-USDA comments 1-17-09.doc 55 KB
NTIA-USDA comments 1-17-09.doc 55 KB

Jim Baller

(Late Submission)
Ex Parte Letter to Secretaries Locke and Vilsack

APPA-NATOA Buy American Letter (6-9-09).doc 104 KB

"Pat Groot" <>

(Late Submission)
Ms. McGuire-Rivera

Please consider our attached comments as you develop final guidelines.
Document provided as a PDF and in Word 2003.


Patricia A. Groot,

Grants Administrator

County of Fluvanna

132 Main Street

Palmyra VA 22963

434.591.1910 x 1081 voice

434.591.1911 fax

711 VA Relay

NTIA federal register on letterhead.pdf 38.05 KB
NTIA federal register on letterhead.doc 54.5 KB

"Kendra Keller" <>

(Late Submission)
The American Farm Bureau's Comments are attached. Please respond to
this email if you have any trouble with the attachment.

broadband-ntia09.0410.pdf 44.02 KB

"James Wasilewski" <>

(Late Submission)
This correspondence came into the Office of the Assistant Secretary on
March 4, 2009.

James V. Wasilewski
Office of Congressional Affairs
National Telecommunications and Information Administration
U.S. Department of Commerce
(202) 482-2476

>>> Ebony Griffin 3/4/2009 11:20:30 AM >>>
Good Morning,

Please see the attached.

Ebony S. Griffin
Administrative Assistant for the Senior Advisor
U.S. Department of Commerce
National Telecommunications and Information Administration
Assistant Secretary's Office

0139 - 03-04-2009 (Brockman) (JW).pdf 1.3 MB
0139 - 03-04-2009 (Brockman) (JW).pdf 1.3 MB

Bruce McFadden

(Late Submission)
See the document submitted below.

ACF15DF.doc 40.5 KB
ACF15DF.doc 40.5 KB

"Close, Colin" <>

(Late Submission)
Please add me to your distribution list for updates about BTOP.
Thank you

COLIN CLOSE | Research & Program Coordinator
Police Department | 965 Sonoma Avenue | Santa Rosa, CA 95404
Tel. (707) 543-3556 | Fax (707) 543-3557

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Barbvara Kasoff

(Late Submission)
April 10, 2009

Ms. Anna Gomez
Deputy Assistant Secretary
National Telecommunications and Information Administration
1401 Constitution Avenue, NW
Washington, DC 20230

Dear Deputy Assistant Secretary Gomez:

On behalf of Women Impacting Public Policy (WIPP), representing more than a half million business owners and women in business, we urge NTIA to consider the critical implications of broadband deployment for small and women-owned businesses.
Businesses of all sizes have been negatively impacted by the recession, but small businesses – a vital engine of economic growth - have been hit especially hard. The American Recovery and Reinvestment Act represents an unprecedented opportunity to help address long-standing challenges that so many American small businesses face. For many small businesses, the road to economic recovery requires access to new and emerging technologies such as broadband. If deployed in a rapid, efficient, and transparent way; NTIA funding will play a crucial role in making broadband more accessible to small businesses owners and will help ensure that the United States can thrive in a 21st century economy.
Specifically, expanding access to advanced telecommunications technologies and services via broadband will spark the creation of new service providers, innovations, and exciting applications for which small businesses depend on to thrive. Such advancements are the most vital and efficient way to deliver information, services, and products such as e-commerce transactions including customer credit-card purchases, online/real-time chat customer assistance and supplier-partner transactions. These services are important touch-points for small businesses to engage customers, suppliers and partners beyond traditional person-to-person, point-of-sale interactions in an Internet global economy. Likewise, small businesses are increasingly seeking global opportunities via broadband connections to reach markets, customers and suppliers outside of traditional local and regional centers.
To that end, we strongly encourage the NTIA to quickly, efficiently, and transparently disperse the stimulus funding to state and local governments so that unserved and underserved small businesses can get on the road to recovery. While financial support and leadership from the federal government is important, state and local governments have the best understanding of what their communities need, can assist in transparent and accountable delivery of broadband, and are in the best position to create effective public-private partnerships to meet specific needs by leveraging private-sector expertise in network construction and management. The best way to gain the benefits of stimulus funding is to ensure that broadband gets to the unserved areas first. That is why we strongly recommend disseminating the funds through an existing model of state-based mapping. It is imperative that these much needed resources get dispersed quickly, without adding network conditions or requirements that will delay or discourage participation by the most capable providers.
We are excited about the prospect of bringing broadband accessibility to all small business owners and are grateful for NTIA’s hard work in ensuring the grants process is fair and efficient. Delivery of next-generation broadband services can not wait – we thank you in advance considering the needs of small businesses as you look forward to spurring economic growth through advanced telecommunications technology.


Barbara Kasoff
Women Impacting Public Policy

Letter to Anna Gomez Deputy Asst Secretary.doc 111 KB

Phillip Brown

(Late Submission)
Comments relating to P.L. 111-5 and P.L. 110-385 are attached.

Policy Filing for NTIA_2009 04 13_with Attachments.pdf 96.91 KB

Christopher Mitchell

(Late Submission)
Comments attached.

BTOPcomments-ILSR.pdf 177.61 KB

Frank Ohrtman

(Late Submission)
Only wireless solutions can support one-to-one computing for our students and time is of the essence in deploying the broadband networks proposed in the ARRA. See

WiMAXinEducation10pgr1.pdf 394.62 KB

eXtension Foundation

(Late Submission)
Please find attached comments pertaining to the American Recovery and Reinvestment Act of 2009 Broadband Initiatives. These comments are provided from the eXtension Foundation, a national Internet-based educational network providing 24/7/365 access to objective, science-based information from land-grant universities and partners nationwide. It is an integral part of and complements the community-based Cooperative Extension System.

ACF7130.pdf 156.47 KB

Scott Lazenby, City Manager, City of Sandy Oregon

(Late Submission)
Give priority to existing municipal ISPs that have already taken on the burden of serving unserved/underserved areas. Consider distributing a portion of the funds to these ISPs by formula (based on population in the area served). See attached.

Comments - NTIA.doc 53 KB
Comments - NTIA.doc 53 KB

Puerto Rico Telephone Company, Inc.

(Late Submission)
See attachment.


"Robert E. Smith" <>

(Late Submission)
Mr. Wilhelm and Ms. Brown:

I have extensive experience in wireless infrastructure (7 yrs) and in City
Management (7 yrs).

I have Master's degrees in Public Administration and in Urban & Regional
Planning, as well as AICP Planning Certification.

I believe I might be able to help the NTIA with the difficult tasks ahead,
and would like to find a position where I could make a difference.

Towards those ends I've attached a resume and references.

Would there be someone I could contact to discuss this further?

Thanks for your time and consideration.


Anvil Partners logo.jpgRobert E. Smith, AICP

314 North 5th Street
Wilmington, NC 28401




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03.19.09.NTIA.BTOP.doc 92.5 KB
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03.19.09.NTIA.BTOP.doc 92.5 KB

"Randy Eckels" <>

(Late Submission)
Please include me on the correspondence list for Broadband Technology
Opportunities Program.



Randy Eckels

Chief Operating Officer

Sting Communications

120 South 16th Street

Lebanon, PA 17042

(717) 270-1979 x4527

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Hardik Bhatt

(Late Submission)
The City of Chicago is filing the attached comments with the National Telecommunications and Information Administration (“NTIA”) of the U.S. Department of Commerce and the Rural Utilities Service (“RUS”) of the U.S. Department of Agriculture in response to the joint request for information on the American Recovery and Reinvestment Act of 2009 Broadband Initiatives.

Docket No. 090309298-9299-01

If you require further clarification on the City of Chicago's comments, please contact Dean Tsilikas, as he will be serving as the initial point of contact.

We thank you for this opportunity to provide our input, and look forward to the overall success of this important initiative.

City of Chicago BTOP Comments.pdf 117.92 KB